starting salary and reckonable service policy … · appendix 1 determination of starting salary 14...

of 24 HullCCG Starting Salaries and Reckonable Service Policy Final

STARTING SALARY AND RECKONABLE

SERVICE POLICY

February 2019

Important: This document can only be considered valid when viewed on the CCG’s website. If this document has been printed or saved to another location, you must check that the version number on your copy matches that of the document online.

If you need this document in a different format or language (e.g. large print, Braille, audio or easy read), please contact us on 01482 344700, or email [email protected], or write to: NHS Hull Clinical Commissioning Group, 2nd Floor, Wilberforce Court, Alfred Gelder Street, Hull HU1 1UY.

HR Policy: HR Starting Salary and Reckonable Service Policy

Date Issued: February 2019

Date to be reviewed: 4 years or if statutory changes are required

mailto:[email protected]

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Policy Title: Starting Salary and Reckonable Service Policy

Supersedes: (Please List) Starting Salaries Policies and Reckonable Service Policy v2.1 and all previous versions.

Description of Amendment(s): 3 Year review, incorporating:

New policy framework document introduced by CCG, July 2018

Reordering and renumbering of some paragraphs and appendices.

Section 2 (Engagement) updated content

Section 3 (Impact Analysis) updated content

Section 7-10 updated content, new Section 11 replaces 10.2 in v2.1

Section 14.3 ii) b. new paragraph added re: temporary movement increment date.

Section 15 (Reckonable Service) and Section 16 (TUPE) updated and added, replacing previous appendices.

Updated Equality Impact Assessment.

This policy will impact on: All CCG employees

Policy Area: Human Resources

Version No: 2.2

Author: eMBED Healthcare Consortium HR Team adapted for local use on behalf of Hull CCG.

Effective Date: February 2019

Review Date: February 2023

Equality Impact Assessment Date:

18/06/2019

APPROVAL RECORD Committee: Date:

Social Partnership Forum Sub Group 14/02/19

Social Partnership Forum 20/02/19

CCG Governing Body 29/03/19

Consultation: SLT Members Consultation

All Staff


CONTENTS

Page

1. INTRODUCTION 4

2. ENGAGEMENT 4

3. IMPACT ANALYSIS 4

3.1 Equality 4

3.2 Bribery Act 2010 5

4. SCOPE 5

5. POLICY PURPOSE AND AIMS 6

6. DEFINITIONS 6

7. ROLES / RESPONSIBILITIES / DUTIES 6

8. IMPLEMENTATION 7

9. TRAINING AND AWARENESS 7

10. MONITORING AND EFFECTIVENESS 7

11. POLICY REVIEW 7

12. REFERENCES 7

13. ASSOCIATED DOCUMENTATION 7

14. PROCEDURE – STARTING SALARY 8

14.1 GENERAL PRINCIPLES 8

14.2 APPOINTMENT OF NEW STAFF JOINING THE NHS OR RE-JOINING

THE NHS

8

14.3 NEW STAFF TRANSFERRING FROM WITHIN THE NHS (INCLUDING

THE CCG)

9

14.4 APPOINTMENT OF STAFF TO THE NHS ‘BANK’ 10

15. RECKONABLE SERVICE 10

16. TUPE TRANSFER 13

APPENDICES

Appendix 1 DETERMINATION OF STARTING SALARY 14

Appendix 2 DETERMINATION OF PREVIOUS SERVICE 16

Appendix 3 EQUALITY IMPACT ASSESSMENT 18


1. INTRODUCTION

1.1 NHS Hull Clinical Commissioning Group (the CCG) is committed to recognising

individual abilities and will ensure that it creates an environment where employees can

thrive and develop and where everyone feels valued and respected.

1.2 The Starting Salary and Reckonable Service Policy has been introduced to ensure a

consistent approach is adopted, by recruiting managers, when establishing the starting

salary and reckonable service for appointments to or within the CCG.

1.3 The 2018 framework agreement on the reform of Agenda for Change (AfC) introduced

provisions to move to a new pay system which included a new 3 year deal covering

2018/19, 2019/20, and 2020/21. This deal incorporated increased starting salaries

across all pay bands, a minimum rate of pay in the NHS to be set at £17,460 from 1

April 2018 – ahead of the Living Wage Foundation Living Wage and provisions to

upskill Band 1 jobs to Band 2 roles during the 3 years of the deal.

1.4 This policy is intended to ensure fairness and equity within this process and is based on

the NHS Terms and Conditions of Service Handbook and should be read in conjunction

with Appendix 23 of these terms and conditions and the CCG’s Pay Progression Policy.

1.5 Reckonable service should be identified by recruiting managers at the same time as

starting salaries (see Section 15)

1.6 The CCG is committed to ensuring that all personal information is managed in

accordance with current data protection legislation, professional codes of practice and

records management and confidentiality guidance. More detailed information can be

found in the CCGs Data Protection and Confidentiality and related policies and

procedures.

2. ENGAGEMENT

2.1 This policy has been developed by the eMBED Health Consortium HR Team in

partnership with employees, managers and trade unions and approved at the Social

Partnership Forum.

3. IMPACT ANALYSIS

3.1 Equality

i. In applying this policy, the CCG will have due regard for the need to eliminate unlawful

discrimination, promote equality of opportunity, and provide for good relations between

people of diverse groups, in particular on the grounds of the following characteristics

protected by the Equality Act (2010); age, disability, gender, gender reassignment,

marriage and civil partnership, pregnancy and maternity, race, religion or belief, and

sexual orientation, in addition to offending background, trade union membership, or any

other personal characteristic.

In developing this policy, an Equality Impact Analysis has been undertaken and the

results are attached at Appendix 3. Initial screening has revealed that the policy

https://www.nhsemployers.org/tchandbook


appears to have an adverse effect on people who share protected characteristics and

further mitigating factors are included in the EIA and EIA action plan.

ii. The application of this policy will be monitored to ensure fair application and a

consistent approach, as follows:

Annual audit of pay to review all decisions to appoint staff above the minimum of the

scale to ensure consistency and to monitor impact and assess whether any further

action is required in any protected group.

These records will be cross referenced with ESR Recruitment and Equality and

Diversity monitoring to ensure a consistent approach across the organisation.

Any deviation from this policy and procedure must be investigated on a case by case

basis to ensure that the principles of fair pay both within equal pay legislation and within

the National agreement on Terms and Conditions are followed.

3.2 Bribery Act 2010

NHS Hull Clinical Commissioning Group has a responsibility to ensure that all staff are

made aware of their duties and responsibilities arising from The Bribery Act 2010.

The Bribery Act 2010 makes it a criminal offence to bribe or be bribed by another person

by offering or requesting a financial or other advantage as a reward or incentive to

perform a relevant function or activity improperly performed. The penalties for any

breaches of the Act are potentially severe. There is no upper limit on the level of fines

that can be imposed and an individual convicted of an offence can face a prison

sentence of up to 10 years.

For further information see http://www.justice.gov.uk/guidance/docs/bribery-act-2010-

quick-start-guide.pdf.

If you require assistance in determining the implications of the Bribery Act please contact

the Local Counter Fraud Specialist on telephone number 01482 866800 or email at

[email protected].

Due consideration has been given to the Bribery Act 2010 in the review of this policy

document. Consistent application and monitoring of this policy will mitigate bribery in

relation to starting salaries.

4. SCOPE

4.1 This policy will apply to all new appointments, transfers or promotions to, or within the

CCG for those employed on Agenda for Change Terms and Conditions of Service.

http://www.justice.gov.uk/guidance/docs/bribery-act-2010-quick-start-guide.pdf

http://www.justice.gov.uk/guidance/docs/bribery-act-2010-quick-start-guide.pdf

mailto:[email protected]


The starting salaries for employees employed on other terms and conditions of service,

i.e. clinical or VSM contracts will be determined in accordance with the relevant terms

and conditions and approval process.

4.2 This policy should be read in conjunction with the Recruitment and Selection Policy, the

Recruitment and Retention Premium Policy and other relevant recruitment policies.

5. POLICY PURPOSE & AIMS

The aim of this policy is to give guidance to recruiting managers to ensure there is a

consistent approach in determining a starting salary and reckonable service.

6. DEFINITIONS

6.1 Unsocial Hours – hours worked any time on Saturdays, Sundays, Public Holidays and

any week day after 8pm or before 6am.

6.2 Overtime – authorised extra time worked in a week above standard hours (37.5 hours)

6.3 Recruitment and Retention Premia – an additional payment made to an individual or

specific group of posts where market pressures would otherwise prevent the employer

from being able to recruit staff to and retain staff in sufficient numbers for the post (s)

concerned at the normal salary for a job of that weight.

6.4 Reckonable Service – is any previous employment in the NHS or listed recognised

organisations (see Section 15)

7. ROLES/RESPONSIBILITIES/DUTIES

7.1 Lead

The Senior Leadership Team is responsible for:

• Ensuring the fair and equitable application of this policy

• Providing advice in relation to the application of this policy

7.2 Employees

New appointees are expected to provide all relevant information/evidence of previous

service and salary details to establish the correct starting salary and reckonable service.

7.3 Line Manager

Recruiting managers are responsible for ensuring that all offers made comply with this

policy.

7.4 Human Resources

The Human Resources Team will provide advice and support on all aspects of this policy

to ensure application and support.


8. IMPLEMENTATION

This policy will be published on the CCG website and all staff will be made aware of its

publication through communications and team meetings.

9. TRAINING & AWARENESS

A copy of the policy will be available on the CCG website. Guidance and support will be provided to all Line Managers, by the HR Team, in the implementation and application of this policy upon request. Training needs will be identified via the appraisal process and training needs analysis.

10. MONITORING AND EFFECTIVENESS

10.1 Records (of Appendix 1 and 2) will be kept in all cases where non NHS service is taken

into account in determining a starting salary and recognising reckonable service. These

records will be cross referenced with ESR Equality and Diversity monitoring to ensure a

consistent approach across the organisation and where it is identified that the

application of the policy is not consistent, appropriate action will be taken.

10.2 The implementation of this policy will be audited at appropriate intervals and reported to

the CCGs Senior Leadership Team.

11. POLICY REVIEW

The policy and procedure will be reviewed after 3 years for the CCG Governing Body in

conjunction with Trade Union representatives. Where review is necessary due to

legislative change, this will happen immediately.

12. REFERENCES

National Minimum Wage Act 1998

Equality Act 2010

Agenda for Change Terms and Conditions

Annual Leave Policy

Recruitment and Selection Policy

Recruitment Retention Premium Policy

Pay Progression Policy

13. ASSOCIATED DOCUMENTATION

Appendix 1 – Determination of Starting Salary

Appendix 2 – Determination of Previous Service

Appendix 3 – Equality Impact Assessment


14. PROCEDURE - STARTING SALARY

This procedure applies to individuals joining or re-joining the NHS as well as transferring

from one NHS organisation to another. The procedure aims to set out clear and fair

principles for determining the starting point at which new starters commence on the

Agenda for Change Pay Band associated with their role.

14.1 GENERAL PRINCIPLES

i. The general principle is that new starters should start on the bottom of the scale and

thereafter progress through pay band ‘gateways’ in accordance with Agenda for Change.

ii. Any deviation from this must be investigated on a case by case basis to ensure that the

principles of fair pay both within equal pay legislation and within the National agreement

on Terms and Conditions are followed. Each case should be discussed with a HR

representative to ensure consistency across the organisation.

iii. Where there is a break in service, depending on the length of the ‘gap’, this service may

be counted in full, in part or not at all towards pay step credit.

iv. Where a recruiting manager believes there is sound business reason for appointing to a

higher pay step point, they must provide clear, documented reasons for giving pay step

credit and seek approval at Director level (Appendix 1) prior to the start date. Requests

will not be considered after the start date.

v. Recruiting managers should ensure that the new starter is aware of the whole

remuneration package, including pension scheme, other benefits, hours of work and

generous annual leave allowance as particularly for non-NHS appointees, these factors

will often make NHS employment more attractive to candidates. Verbal offers of

employment should not commit to a starting salary above the bottom of the scale.

vi. Any additional payments such as unsocial hours, overtime or recruitment and retention

premia should NOT be taken into account in the determining of a starting salary.

14.2 APPOINTMENT OF NEW STAFF JOINING THE NHS FOR THE FIRST TIME OR RE-

JOINING THE NHS

i. Offers will normally be made at the minimum of the relevant pay band for those who

have had no or less than 12 months’ aggregated previous relevant experience of the role

to which they are recruited.

ii. Current salary should NOT be used as a way of determining starting salary, but may be

a factor in deciding to take the level of any relevant previous experience into account.

iii. Directly relevant experience, at the same level of responsibility as, or higher than the

new post, may be taken into account in determining starting salary. Only whole years of

experience should be credited when the knowledge, skills and experience are directly

transferable. Experience at a higher level may not be directly relevant. Where

experience is not like for like, e.g. a registered nurse working in a nursing home, it may

be appropriate to consider the experience and assess what element is directly relevant

to the post appointed to.


iv. Documentary evidence must be provided for any periods of employment that count

towards a higher than the minimum starting salary.

v. In all cases where a new member of staff is appointed on a starting salary above the

minimum point of the pay band the recruiting manager must be able to justify the basis

for pay step credit and must first obtain approval from the relevant Director. No

employee will be put on the payroll above the minimum of the scale unless a signed

Appendix 1 form is attached to the starter documentation.

vi. Managers must also ensure that new starters are not placed on a point on the band that

would put them in a better position than existing staff with the same or similar experience

or those who have gained similar experience within the NHS.

vii. New staff appointed from outside the NHS will have an pay step date of the anniversary

of their NHS appointment.

14.3 NEW STAFF TRANSFERRING FROM WITHIN THE NHS (INCLUDING THE CCG)

i. Staff Moving to the Same Pay Band

Staff who transfer to a post on the same pay band will remain on the same salary point

with the same pay step date.

ii. Staff Moving to a Higher Pay Band

a. Permanent Movement to Higher Pay Band - Employees appointed to a higher

pay band will start on the minimum of the pay band. If this point is lower or equal

to their current salary, they will receive a pay increase to the first point on the band

which would deliver an increase to pay. The anniversary date of any promotion

becomes the employee’s pay step date, except for professional roles covered by

Annex 20 of the NHS Terms and Conditions of Service who will retain their original

pay step date.

b. Temporary Movement into a Higher Pay Band - Employees appointed to a

higher band on a temporary basis should start at the minimum of the new pay

band or, if this would result in no pay increase the first pay point in the band which

would deliver an increase in pay. Refer to other relevant policies for further

information.

Where temporary movement into a higher pay band results in only one extra pay

point the pay step date remains the same. Where temporary movement results in

more than one extra pay point the pay step date for the period of the temporary

movement becomes the date the movement began.

iii. Staff Moving to a Lower Pay Band

a. Same area of work – There are various reasons why a member of staff may wish

to voluntarily take a lower graded post but in the same field of work. In such

cases, employees appointed to a lower pay band will remain on their current spine

point. If this point does not fall within the new pay band, they will start on the

https://www.nhsemployers.org/tchandbook/annex-16-to-20/annex-20-development-of-professional-roles


maximum spine point of the new pay band. Individuals will retain their existing pay

step date.

b. Staff Moving to a Different Area of Work - Sometimes individuals decide to

move to a new post within a different area of work of their own volition e.g. a

clinical person applying for an office based role. In these cases the starting salary

will normally be the minimum of the relevant pay band and may involve a decrease

in salary for an individual. The starting salary may take into consideration the

knowledge and skills required for the post (see Sections 14.2 iii) and 14.2 v)).

However, it would not be the case that they would automatically be entitled to keep

their existing salary. This also applies in cases where the member of staff is

moving to the same band in a different area of work.

Where an individual re-trains in a different area of work for wider service or

operational reasons i.e. not of their own volition, with the explicit agreement of the

CCG their existing level of pay should be protected in line with the CCG’s

protection arrangements.

iv. Staff Moving to a Lower Pay Band and later Moving Back to Original Band - In

some occasions staff may voluntarily move to a lower band and later they may return to

the higher band. In these situations the new salary should be calculated by using the

same rationale as out lined in Section 14.3 ii).

14.4 APPOINTMENT OF STAFF TO THE NHS ‘BANK’

i. Offers will normally be made at the minimum of the relevant pay band for those who join

the NHS ‘Bank’, unless an individual has been employed previously in the same role

(permanent/temporary/fixed term) within the NHS, in which case they will be appointed

on their most recent pay point. This will not apply if an individual has returned following

an absence period of over 12 months in which case the recruiting manager will appoint

them to a point which reflects their knowledge and previous experience, as in Section

14.2

ii. All staff will have an pay step date of the anniversary of their appointment to the Bank

15. RECKONABLE SERVICE

15.1 Reckonable Service is any previous employment in the NHS or listed recognised

organisations (refer to Section 12 of the NHS Terms and Conditions of Service

Handbook).

15.2 Reckonable Service applies to individuals returning to the NHS, transferring within the

NHS or joining the NHS with service from one of the recognised organisations listed

below:

i. NHS Employment

For the purposes of NHS reckonable service, the following organisations shall be

regarded as NHS employment:

https://www.nhsemployers.org/tchandbook/part-3-terms-and-conditions-of-service/section-12-contractual-continuity-of-service


England:

NHS England

Clinical Commissioning Groups

NHS Trusts including Foundation Trusts

Special Health Authorities

The Health and Social Care Information Centre

National Institute for Health and Clinical Excellence

Health Education England (HEE)

Northern Ireland:

Health Boards

Trusts

Special Agencies

Public Health Agency

Business Services Organisation

Patient and Client Council

Scotland:

Health Boards

Special Health Boards

Wales:

NHS Trusts

Local Health Boards

and any predecessor or successor of the above organisations.

ii. Additional Recognised Organisations.

In addition to service with the NHS, for the purposes of annual leave, the CCG includes

service with the following organisations:

GP Practice or NHS Dentist working exclusively on NHS Work

County Council / City Council / Social Services.

The Department of Health

Social Enterprise delivering NHS services

Employers have discretion to take into account any period or periods of employment with

employers outside the NHS, where these are judged to be relevant to NHS employment.

15.3 For service with the above additional recognised organisations to count, previous

service needs to be comparable and in highly relevant roles. For these purposes, a

highly relevant role is defined as a role which is within the same area of work to which

they have been recruited to, e.g. children’s services, finance, health or social care

records, therapy. Guidance from a HR Representative should be sought to confirm

whether a role is deemed to be highly relevant.

15.4 Any reckonable service must be recorded using the ‘Determination of Previous Service’

form (Appendix 1). This form should be completed by the new employee and signed by

the manager to confirm that they have seen evidence of all reckonable service, and then

sent to payroll with the new employee’s starter documents and a copy placed on their

personal file.

15.5 Calculating Reckonable Service

The rules for determining entitlement for redundancy, maternity, sick pay and annual

leave are different, so this guidance is designed to set out the rules for calculating

reckonable service under the different circumstances which may arise.


Annual Leave –all previous period(s) of NHS service or service with a listed recognised

organisation may be aggregated and count as reckonable service towards the

employee’s entitlement to annual leave, regardless of any breaks in employment. The

previous experience within an additional recognised organisation must be in a

comparable and highly relevant role.

Sick Leave – previous period(s) of NHS service (only) will be counted towards

entitlement to sick leave/pay where there has been a break in service of twelve months

or less.

Maternity Leave – employees can have a break in service of three months or less and

not affect their entitlement to maternity leave. Employees must have twelve months

continuous NHS service at the beginning of the eleventh week before the expected week

of childbirth in order to be eligible for Occupational Maternity Pay.

Redundancy –to be eligible for a contractual redundancy payment there must not have

been a break in NHS service of more than a week (7-days, measured Sunday to

Saturday) between periods of employment.

Pay Step Date – for newly appointed (including those with a break in service) or

promoted staff the pay step date will be the date they take up their post. All other staff

retain their current pay step date.

All other terms and conditions of service - For these purposes, the CCG will include

employment with a break in service of up to a maximum of 3 months at any one time,

unless otherwise stated.

15.7 For the purposes of calculating entitlements, the following do not count as a break in

employment:

Maternity Leave Adoption Leave

Paternity Leave Sick Leave

Annual Leave Carer / Compassionate Leave

Parental Leave Career/Employment Break.

15.8 All contractual entitlements will accrue as normal during all of the above periods of

absence, except during the Career/Employment Break. An employee returning from an

Employment Break will receive the same entitlements they had accrued before they

started their Employment Break. Pay progression will continue as normal during

Maternity / Adoption Leave, Birth Leave, Sick Leave, Annual Leave, Carer /

Compassionate Leave and Parental Leave, but not during an Employment Break. An

employee returning from an Employment Break, or other special leave, will resume their

pay progression from the point at which they started their leave.

15.9 When an employee TUPE transfers out of NHS employment to a non NHS employer and

then returns to NHS employment, their continuous service with the non NHS employer

will count as reckonable in respect of NHS agreements on sick pay, annual leave and

pay step credit.

15.10 Any service with the NHS Bank is counted as reckonable service when the employee

has worked for a minimum of 12 months and has worked at least 488 hours. For all


entitlements, the above definition equates to one year’s service and only full years may

be counted.

15.11 For additional guidance or support, please contact a HR Representative.

16. TUPE TRANSFER

Staff who have previously worked for the NHS may have been TUPE transferred into a non

NHS organisation. The CCG have agreed to recognise service as continuous and reckonable

providing:

1. The individual TUPE transferred to the non NHS organisation (and therefore had no

choice over the move)

2. The individual remains in the role in which they transferred to the non NHS organisation

on. If individuals move into a different role within the TUPE transferred organisation as a

result of Suitable Alternative Employment (SAE) which has been imposed on them, the

CCG may also recognise this service. If an individual has voluntarily chosen to change

jobs within the TUPE transferred organisation then this will not be recognised.

3. The TUPE transfer was within a three year period of joining the CCG (with no breaks).

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APPENDIX 1 - DETERMINATION OF STARTING SALARY

Name of Candidate Job Title

AfC Pay Band Spine Point

Proposed Starting Salary Date of Appointment

Reason for starting point above the minimum of the pay band. Include consideration of impact on colleagues / team / department.


Previous Experience:

Start Date End Date Organisation Job Title Previous Salary/Grade

New staff appointed from outside the NHS will normally commence on the minimum point of a pay band. Directly relevant experience at the same level of responsibility as the new post may be taken into account in determining a starting salary. Only whole years of experience should be credited when the knowledge, skills and experience are directly transferrable. Proposed By (Line Manager)

Agreed By (HR Manager) Approved By (Director)

Name

Name

Name

Signature

Signature

Signature

Date

Date

Date

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APPENDIX 2 - DETERMINATION OF PREVIOUS SERVICE

In all cases, appointees will need to provide documentary evidence of any employment they wish to be considered as reckonable service, e.g. an offer

letter or contract of employment, payslips, P60 or a letter from the employing organisation. Employees may state their reckonable service on the form

below and provide the necessary documentation at a later date. However failure to provide this information or provision of incorrect information will

lead to appropriate adjustments being made. If employees do not wish to sign a statement to this effect, they will receive the minimum entitlements

until they provide the relevant documentary evidence, at which point any entitlement will be backdated appropriately.

The Starting Salaries Policy identifies those organisations which are recognised for the calculation of previous service. Please note that any breaks in

service may mean that previous employment is not included for the purposes of certain entitlements.

Please give details of relevant previous service below:

Start Date End Date Job Title Salary Band & SCP Organisation Evidence

£ Band:

Point:

£ Band:

Point:

£ Band:

Point:

£ Band:

Point:

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At the time of, or within 6 weeks* of, the submission of this form, you must submit a written statement of employment from a previous organisation to your manager, in order to confirm the information. Failure to submit this or contradiction of any information provided may result in an overpayment of salary or a more generous entitlement under the terms and conditions of service. If so, you will be informed of the discrepancy and it will be recovered appropriately. Please Note, current salaries will not be used as a way of determining starting salary, but may be a factor in deciding to take relevant previous

experience into account. Managers must ensure that new starters are not placed on a point on the band that would put them in a better position than

existing staff or those who have gained similar experience within the NHS.

Any queries should be referred to a HR Representative to ensure consistency across the organisation.

*this time period may be extended in exceptional circumstances

I wish to have my entitlements and starting salary determined under the method outlined above. I understand and agree that any overpayments

resulting from the application of this method will be recovered in accordance with the Overpayments Policy.

Employee’s Signature: Print Name: Date:

Manager’s Signature: Print Name: Date:

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APPENDIX 3

HR / Corporate Policy Equality Impact Analysis:

Policy / Project / Function:

Starting Salary and Reckonable Service Policy v2.2

Date of Analysis: 2 January 2019

Completed by: (Name and Department)

eMBED Health Consortium HR Team.

What are the aims and intended effects of this policy, project or function?

To ensure a consistent approach is adopted, by recruiting managers, when establishing the starting salary for appointments to or within the CCG. AfC requires “that all NHS employers should have fair and non-discriminatory systems for recruiting, developing and promoting people.” (Para 31.1)

Are there any significant changes to previous policy likely to have an impact on staff / other stakeholder groups?

No

Please list any other policies that are related to or referred to as part of this analysis

Agenda for Change Terms and Conditions

Annual Leave Policy

Recruitment and Selection Policy

Recruitment Retention Premium Policy

Who will the policy, project or function affect?

All Employees of the CCG

Members of the Public (during the recruitment

process)

What engagement / consultation has been done, or is planned for this policy and the equality impact assessment?

Consultation has taken place both locally and nationally with Trade Unions and staff

Promoting Inclusivity and Hull CCG’s Equality Objectives. How does the project, service or function contribute towards our aims of eliminating

The Starting Salaries Policy has been developed to ensure a consistent approach is adopted by recruiting managers when establishing the starting salary for appointments to or within the CCG. AfC requires “that all NHS employers should have fair

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discrimination and promoting equality and diversity within our organisation? How does the policy promote our equality objectives: 1. Ensure patients and public have improved

access to information and minimise

communications barriers

2. To ensure and provide evidence that

equality is consciously considered in all

commissioning activities and ownership of

this is part of everyone’s day-to-day job

3. Recruit and maintain a well-supported,

skilled workforce, which is representative

of the population we serve

4. Ensure the that NHS Hull Clinical

Commissioning Group is welcoming and

inclusive to people from all backgrounds

and with a range of access needs

and non-discriminatory systems for recruiting, developing and promoting people.” (Para 31.1)

Equality Data

Is any Equality Data available relating to the use or implementation of this policy, project or function? Equality data is internal or external information that may indicate how the activity being analysed can affect different groups of people who share the nine Protected Characteristics – referred to hereafter as ‘Equality Groups’. Examples of Equality Data include: (this list is not definitive) 1: Recruitment data, e.g. applications compared to the population profile, application success rates 2: Complaints by groups who share / represent protected characteristics 4: Grievances or decisions upheld and dismissed by protected characteristic group 5: Insight gained through engagement

Yes

ESR Workforce Profile Data No Where you have answered yes, please incorporate this data when performing the Equality Impact Assessment Test (the next section of this document). If you answered No, what information will you use to assess impact? Please note that due to the small number of staff employed by the CCG, data with returns small enough to identity individuals cannot be published. However, the data should still be analysed as part of the EIA process, and where it is possible to identify trends or issues, these should be recorded in the EIA.

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Employee Equality Data

General Total number of employees in the CCG is 100

Age 8.0% of staff are under 30

73.0% of staff aged 30 - 55

19.0% of staff are over 55

Gender 68.0% of staff employed are female

32.0% of staff employed are male

Race / Nationality

89.0% of staff employed in the CCG declared themselves as White

British

9.0% of staff are not stated/undefined.

1.0% of staff declared themselves as White Other

1.0% of staff declared themselves as Asian

Disability

68.0% of staff employed have declared themselves as having no

disability

29.0% of staff did not declare /undefined

3.0% of staff have declared a disability

Sexual Orientation

63.0% of staff described themselves as heterosexual

35.0% of staff did not wish to respond /undefined

2.0% of staff described themselves as gay/lesbian/bisexual

Gender Reassignment No information available

Religion / Belief

45.0% of staff declared themselves as Christian.

41.0% were undefined or did not wish to declare

11.0 % of staff declared themselves as Atheist

1.0% of staff declared themselves as Islamic 2.0% of staff declared other religions or beliefs

Pregnancy and

Maternity No information available

Marriage and civil

partnership

61.0% of employees are married.

22.0% of employees are single

7.0% of employees are divorced or legally separated

6.0% of employees were undefined or did not wish to declare

2.0% of employees are widowed. 2.0% of employees are in a civil partnership

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Assessing Impact

Is this policy (or the implementation of this policy) likely to have a particular impact on any of the protected characteristic groups? (Based on analysis of the data / insights gathered through engagement, or your knowledge of the substance of this policy)

Protected Characteristic: No Impact:

Positive Impact:

Negative Impact:

Evidence of impact and, if applicable, justification where a Genuine Determining Reason1 exists (see footnote below – seek further advice in this case)

It is anticipated that these guidelines will have a positive impact as they support policy writers to complete meaningful EIAs, by providing this template and a range of potential issues to consider across the protected characteristics below. There may of course be other issues relevant to your policy, not listed below, and some of the issues listed below may not be relevant to your policy.

Gender

Potential Negative Impact-female employees. AfC provides for incremental progression through salary bands which is maintained on transfers within the NHS. Appointees from outside the NHS can similarly benefit from their relevant years of service being taken into account in determining appointment salaries. This policy therefore potentially favours employees who have fewer employment breaks as they will have more years of service but this is a long-standing and agreed practice for recognising relevant experience, knowledge and skills and is subject to review of performance. Breaks in employment can lead to women having less service due to caring responsibilities, Carers UK support that women have greater caring responsibilities in Carers UK (nd) 10 Facts About Women and Caring in the UK on International Women’s Day. This is potentially a negative impact. However this is mitigated by a range of other employment policies that allow flexibility in hours of work and leave arrangements to reduce the need for employment breaks and allow staff to continue to progress through the pay bands. In addition robust recruitment processes will ensure that capability to perform a role rather than length of time in the role support a good appointment.

1 The action is proportionate to the legitimate aims of the organisation (please seek further advice)

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Age

Potential Positive Impact - older employees. Potential Negative Impact –younger employees. AfC provides for incremental progression through salary bands which is maintained on transfers within the NHS. Appointees from outside the NHS can similarly benefit from their number of years of directly relevant experience being taken into account in determining appointment salaries. This policy therefore potentially favours older employees as they will have more years of service but this is a long-standing and agreed practice for recognising relevant experience, knowledge and skills and is subject to review of performance. Age is not taken into account when the decision to shortlist and/or interview is taken, as this information is not available to the recruiter at that stage. Once appointed a younger employee may be on a lower point on the pay scale, having less years of service/experience than an older employee doing the same role. However, increment payments are made consistently to all employees and progression through incremental pay points are conditional on individuals demonstrating they meet performance requirements. During recruitment, AfC requires that “Emphasis should be placed on quality, rather than length of experience, and consideration should be given to experience gained outside paid employment” (Para 31.7) i.e. quality of experience not the age of the applicant.

Race / ethnicity / nationality

The policy is in line with agenda for change terms and conditions and application of the policy is fair and consistent regardless of race and therefore does not have a negative impact on this protected characteristic.

Disability


Religion or Belief


Sexual Orientation


Pregnancy and Maternity

A period of maternity leave counts towards reckonable service and therefore does not have an adverse impact on this protected characteristic. Application of the policy is fair and consistent.

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Transgender / Gender reassignment

The policy is in line with agenda for change terms and conditions and application of the policy is fair and consistent and therefore does not have a negative impact on this protected characteristic.

Marriage or civil partnership

The policy is in line with agenda for change terms and conditions and application of the policy is fair and consistent and therefore does not have a negative impact on this protected characteristic.

Action Planning:

As a result of performing this analysis, what actions are proposed to remove or reduce any risks of adverse impact or strengthen the promotion of equality?

Identified Risk: Recommended Actions: Responsible Lead: Completion Date: Review Date:

The application of this policy should be regularly monitored to ensure a consistent approach

1. Annual audit of pay to review all decisions to appoint staff above the minimum of the scale to ensure consistency and to monitor impact and assess whether any further action is required in any protected group including those risk identified under age and gender.

Head of HR

2.These records will be cross referenced with ESR Recruitment and Equality and Diversity monitoring to ensure a consistent approach across the organisation

3. Any deviation from this policy and procedure must be investigated on a case by case basis to ensure that the principles of fair pay both within equal pay legislation and within the National agreement on Terms and Conditions are followed.

4. Recruitment decisions should be routinely monitored and reviewed to ensure a fair, transparent and competency based approach has been demonstrated.

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Sign-off

All policy EIAs must be signed off by Mike Napier, Associate Director of Corporate Affairs

I agree with this assessment / action plan

If disagree, state action/s required, reasons and details of who is to carry them out with timescales:

Signed:

Date: 18.06.19

starting salary and reckonable service policy … · appendix 1 determination of starting salary 14...

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